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Andrew Rose (UK)

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On Monday 11 March, the UK Export Control Joint Unit (the ā€œECJUā€) announced amendments to its Export Control Order 2008 (the ā€œ2008 Orderā€) and Council Regulation (EC) No 428/2009 (the ā€œRetained Dual-Use Regulationā€), pursuant to the Export Control (Amendment) Regulations 2024 (the ā€œRegulationsā€). The Regulations will come into force on 1 April 2024 and will amend Schedules 2 and 3 of the 2008 Order, as well as Annex I of the Retained Dual-Use Regulation. Amendments…

As part of the EUā€™s 12th package of sanctions against Russia, adopted on 19 December 2023 (see our previous blog post here), the EU introduced a requirement under Article 12g of Regulation 833/2014 which requires EU exporters to include wording in certain goods contracts prohibiting the re-export of the goods to Russia and providing for ā€œadequate remediesā€ in the event of a breach, in order to combat the circumvention of EU export bans and more…

On 14 December 2023, the Office of Financial Sanctions Implementation (ā€œOFSIā€) published its 2022-2023 annual review (see here). The review summarises OFSI’s activities over the 2022-2023 financial year and looks ahead at trends and OFSI’s priorities for the next year. Russia Sanctions The report has a particular focus on the UK’s expanded Russia sanctions regime, stating that by 31 March 2023, “130 oligarchs and family members” who had a combined net worth of around Ā£145…

On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russiaā€™s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a…